Trade-Based Money Laundering

Abstract

Being a Certified Anti-Money Laundering Specialist since 2016, and an expert in combatting money laundering and terrorist financing for a period exceeding 9 years, where I worked in three Alfa banks in Lebanon (BLOM, Bankmed, and Creditbank); and considering my current position as Head of Legal Compliance at Creditbank sal, I prepared this thesis on the trends and developments of Trade-based Money Laundering (TBML) and the related risks and challenges faced by the banking sector. As one of the basic methods in the money laundering and terrorist financing framework, this study aims to identify and explore the methods used in TBML. We will highlight on how criminals are using TBML to conceal the features of their crime within routine transactions that result from commercial activities and international trade in its various aspects and forms. TBML happens in countless ways where the criminals have access to the financial institutions, particularly, the banking sector, and are able to hide the source of their funds and make it appear as legitimate. On the other hand, we will focus on the difficulties faced by the banking sector in combating this type of money laundering and the gaps that the criminals exploit to launder their proceeds through international trade. We will also shed the light on the international legislations and laws, global recommendations, exchange of information between countries, and policies and procedures adopted by the banks, in order to limit the expansion of TBML. The main objective of this study is to give a comprehensive idea about the concept of TBML and spreading the knowledge and increasing cultural awareness regarding the risks that this crime could pose, and to find modern and effective ways to fight it. In my research, I relied on live interviews with specialists in combating money laundering and terrorist financing, and on several real cases that took place in the banking sector.